This submission responds to the Exposure Draft Airports (Environment Protection) Regulations 2026 and assesses the implications for airport-based freight and logistics operations. While modernising environmental regulation is important, the draft introduces significant legal, operational and investment risks for complex, multi-tenant airport precincts that sustain nationally critical freight movements. Key issues include the removal of the polluter-pays principle, expanded compliance and liability exposure for routine activities, uncertainty created by investigation thresholds embedded directly in regulation, and governance limitations associated with the proposed Airport Environment Officer model. These challenges are intensified by an unusually compressed consultation period ahead of the April 2026 sunsetting deadline.
The submission recommends a staged, risk-managed approach that maintains regulatory continuity in the short term, with substantive reform advanced through the Aviation White Paper process, supported by appropriate consultation and impact analysis.